Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
An assessment order must bear a signature, and an unsigned order is invalid. The High Court also recognised practical difficulties in accessing orders uploaded on the portal and held that delay in invoking writ jurisdiction can be overlooked where the assessment suffers from a patent irregularity, while balancing taxpayer hardship against revenue protection. The unsigned assessment orders were set aside and the matter was remanded for fresh assessment after hearing, subject to deposit of 20% of the disputed tax, adjustment of amounts already paid or recovered, and exclusion of the writ period for limitation.
An assessment order must bear a signature, and an unsigned order is invalid. The High Court also recognised practical difficulties in accessing orders uploaded on the portal and held that delay in invoking writ jurisdiction can be overlooked where the assessment suffers from a patent irregularity, while balancing taxpayer hardship against revenue protection. The unsigned assessment orders were set aside and the matter was remanded for fresh assessment after hearing, subject to deposit of 20% of the disputed tax, adjustment of amounts already paid or recovered, and exclusion of the writ period for limitation.
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